Page 39 - PRIVATE & CONFIDENTIAL

USE OF DISCLOSURE INFORMATION

Disclosure information is only used for the specific purpose for which it was requested
and for which the candidate/employee’s full consent has been given.

RETENTION

Once a recruitment (or other relevant) decision has been made about a
candidate/employee, the company does not keep disclosure information for any
longer than is absolutely necessary. This is generally for a period of up to six months,
to allow for the consideration and resolution of any disputes or complaints. If, in very
exceptional circumstances, it is considered necessary to keep disclosure information
for longer than six months, the company will consult the DBS and will give full
consideration to the rights of the individual under the Data Protection Act 1998 before
doing so. Throughout this time the usual conditions regarding safe storage and strictly
controlled access will prevail.

DISPOSAL

Once the retention period has elapsed, the company will ensure that any disclosure
information is immediately destroyed by secure means, e.g. by shredding, pulping or
burning. While awaiting destruction, disclosure information will not be kept in any
insecure receptacle (e.g. waste bin or confidential waste sack).

The company will not keep any photocopy or other image of the disclosure
Information or any copy or representation of the contents of a disclosure. However,
notwithstanding the above, the company may keep a record of the date of issue of a
disclosure, the name of the subject, the type of disclosure requested, the position in
relation to which the disclosure was requested, the unique reference number of the
disclosure and the details of the recruitment decision taken.

ACTING AS AN UMBERELLA BODY

Before acting as an umbrella body (one which countersigns
applications and receives disclosure information on behalf of
other employers or recruiting organisations), the company will
take all reasonable steps to ensure that it can comply fully with
the DBS Code of Practice.

The company will also take all reasonable steps to ensure that it
will handle, use, store, retain and dispose of disclosure
information in full compliance with the DBS Code and in full
accordance with this policy. The company will also ensure that
any organisation or individual at whose request applications for
disclosure are countersigned, has a relevant written policy and, if
necessary, will provide a model policy for that organisation or
individual to use or adapt for this purpose.